PRIVACY POLICY

Basic policy on handling personal data

TBWA\HAKUHODO handles personal data that it collects independently; personal data provided by client companies, media companies and affiliated companies; and personal data about our executives and employees and those of our affiliated companies appropriately in line with applicable laws, industry standards and TBWA\HAKUHODO’s own internal regulations.

Personal data utilized by TBWA\HAKUHODO

TBWA\HAKUHODO in principle utilizes statistically processed personal data. However from time to time, TBWA\HAKUHODO also utilizes data such as the following that could potentially identify individuals:

1. Data collected from questionnaire surveys, group interviews or other R&D and research activities that could potentially identify individuals.

2. Data collected from entrants in promotional campaigns consigned to TBWA\HAKUHODO by client companies or media owners that could potentially identify individuals.

Appropriate acquisition and utilization of personal data from individuals:

When acquiring personal information from individuals, TBWA\HAKUHODO first explains how the data will be utilized and whether the information may be provided to a third party, as well as how the data will be utilized in that case. Furthermore, should there be any change to the purpose of the data or the entities to which it may be provided, we inform the individual concerned. In case we do not obtain their agreement, utilization of the data is restricted to that which has been agreed to. We comply with all requests not to utilize any or all of the data. We also strive to maintain the accuracy of the data, and comply with all requests to disclose, amend or delete the data.

3)

Confirmation of the appropriateness of personal data obtained in business dealings and its appropriate utilization and security control:

TBWA\AHAKUHODO confirms how personal data from client companies or media owners obtained in conducting our business was collected and the scope of use consented to. We utilize the data appropriately in line with the requirements of the business affiliate and our own internal regulations.

4)

Executive and employee education:

TBWA\HAKUHODO promotes appropriate utilization of personal data and adherence to all regulations and rules through regularly conducted educational programs for executives and employees that convey the importance of personal data protection, legal requirements, management systems, regulations for handling the data and measures in case of breach of regulations.

5)

Establishment of data management systems:

To protect personal data, TBWA\HAKUHODO has defined internal management and responsibility systems, and selected staff responsible for the management of personal information.

6)

Clarification of information handling:

TBWA\HAKUHODO has established regulations regarding the safe and appropriate handling of personal data including viewing, utilization, storage, destruction and return of such data, and abides by these through the offices of staff responsible for the management of personal information.

7)

Measures against unauthorized access:

TBWA\HAKUHODO has built appropriate data systems, data management systems and other measures to prevent theft, loss, manipulation or destruction of personal data due to unauthorized access.

8)

Ensuring safety of outsourced information processing:

When outsourcing personal data processing, TBWA\HAKUHODO selects contractors it has confirmed as able to ensure safe management of information in line with our regulations, and provides appropriate supervision of these contractors.

9)

Establishment of immediate response system in case of problems:

In the unlikely event a problem arises, TBWA\HAKUHODO has established structures to quickly and accurately detect the problem, make appropriate decisions, and take appropriate action.

10)

On-going improvement:

TBWA\HAKUHODO makes efforts to constantly improve by monitoring personal information management and responding to changes in the external environment.